air pollution from vehicles. In order to build and operate a CUCC, an authority is likely to require funding because, as noted in Section 2.11 of the Literature Review, any cost savings achieved by carriers in not delivering 'the last mile' are typically not passed on, and under this structure would have little or no ability to be passed on.

The legislative review has not revealed any clear existing powers that could compel delivery companies to deliver to a CUCC. There is an argument, but a far from compelling one, that the power to require deliveries be made to/from CUCCs lies in section 101(3)(c) Postal Services Act 2000 under which the Secretary of State can give directions relating to the provision of postal services to any or all postal operators for reasons including to facilitate the discharge of an international obligation, which could include the Paris Agreement 2015. Section 27(3) Postal Services Act 2011 defines 'postal operators' broadly as 'a person who provides: (a) the service of conveying postal packets (letter, parcel, packet, or other article transmissible by post (post is undefined in that act)) from one place to another by post; or (b) any of the incidental services of receiving, collecting, sorting, and delivering postal packets. The ability for this power to extend to all delivery companies is not clear cut, but would seem at least arguable and may turn on the definition of 'post' and an argument that a person can be a postal operator if delivering parcels, which can be transmitted by post, but that such parcels need not actually be being transmitted by post in order for the person to be a postal operator (were post deemed to be something different from delivery of parcels). Were an argument that all delivery companies were postal operators to succeed, such classification may have further implications under the Postal Services Acts which are beyond the scope of this review.

The legislative review has not revealed any clear existing powers that would permit an authority, or other carrier, to complete the last mile of a package's delivery from a CUCC, without the agreement of the delivery company that the original order had been placed with. Therefore, unless new legislation is passed, cooperation of the delivery companies will be required in order to effect delivery to the final destination.

Standard contractual provisions would be expected to apply with respect to the transfer of liability for loss or damage to the package from the original carrier to the carrier for the last mile. Liability would also need to be agreed with the CUCC operator in respect of the transfer of risk while the package was in the CUCC between delivery by the original carrier and collection by the last mile carrier. There is no legislation which would compel the liability level of one carrier to be the same as another carrier for different parts of the package's journey.

The Literature Review identified three different models of consolidation centre that have been successfully utilised throughout Europe: Vicenza, Utrecht, and Sweden. Although these were used in different legal jurisdictions and their legal bases not examined for the purposes of this report, this section sets out some commentary relating to the implementation of similar schemes under current legislation in England and Wales.

The local government of the city of Vicenza took, in summary, the following actions:

A number of international express carriers challenged the validity of the municipal ordinances in court. In the court of first instance, the express carriers were successful, and the ordinances were annulled. However, on appeal, the Italian State Council overturned the lower court ruling. No further appeals were made by the

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